Andy(posted 7699 days ago)Am currently putting together a defence & counterclaim as well. Am quite happy to look at your document although I AM NOT a litigation lawyer. I suggest your friend gets legal advice if he can afford it, although this is quite a niche area and you may need to help the solicitor by giving him some info off this site. SARN the bank as a priority and also write to Wragge & Co and ask them to provide all documents to prove their claim ie signed and dated mortgage offer signed and properly executed deed of mortgage evidence of marketing material for sale of any MIG, endowment etc. There is stuff on this site about what you should ask for.
If you are intending to file a defence, file an acknowledgement of service. This will allow you up to 28 days to file your defence. Remember that the Claim is deemed to be served 2 days after the postmark on the envelope so make sure you keep this.
If your friend cannot afford a solicitor try the CAB.
As a final shot the BAR Pro Bono Unit may provide a Barrister free of charge. http://www.barprobono.org.uk/. I know of them but haven't attempted to secure a barrister (yet).
Good luck Allye